ARTICLE
30 December 2016

NFA Specifies Effective Date Of Enhanced Form PQR And PR Reporting Requirements

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The amendment and the Interpretive Notice for Forms PQR and PR will become effective as of the quarter ending on June 30, 2017.
United States Finance and Banking
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The NFA notified member firms that the CFTC approved a proposed amendment to NFA Compliance Rule 2-46 and a related Interpretive Notice. The amendment and notice require commodity pool operators ("CPOs") and commodity trading advisors ("CTAs") to report two financial ratios regarding a CPO or CTA's financial condition on the quarterly Forms PQR and PR. The NFA stated that it will use this information to monitor the financial condition of CPOs and CTAs. The amendment and the Interpretive Notice for Forms PQR and PR will become effective as of the quarter ending on June 30, 2017.

In order to help CPO and CTA members understand the new reporting requirements and calculation of the ratios, the NFA indicated that it will: (i) produce a webinar early next year, (ii) include guidance in Forms PQR and PR in order to provide additional information on how to complete the new data fields, and (iii) work with NFA member firms during examinations in order to ensure that firms are calculating the ratios correctly.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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